The State Railroad Tax Cases were a series of cases heard by the United States Supreme Court in 1873. The cases involved the constitutionality of state taxes imposed on the property of railroad companies. The plaintiffs, a group of railroad companies, argued that the taxes were unconstitutional because they violated the Commerce Clause of the United States Constitution. The defendants, a group of state tax collectors, argued that the taxes were constitutional because they were imposed on the property of the railroad companies, not on the interstate commerce itself. The Supreme Court ultimately sided with the defendants, ruling that the taxes were constitutional. The Court held that the taxes were not a burden on interstate commerce, as they were imposed on the property of the railroad companies, not on the interstate commerce itself. The Court also held that the taxes were not discriminatory, as they were imposed on all railroad companies, regardless of their interstate commerce activities. The Court also noted that the taxes were not excessive, as they were imposed in proportion to the value of the property owned by the railroad companies. In conclusion, the Supreme Court ruled that the state taxes imposed on the property of railroad companies were constitutional. The Court held that the taxes were not a burden on interstate commerce, were not discriminatory, and were not excessive.

In the case of Taylor, Collector et al. v. Secor et al., the dissenting opinion argued that a state tax imposed on railroad companies was unconstitutional and violated the Due Process Clause of the Fourteenth Amendment. The majority had ruled in favor of upholding this tax, but Justice Field dissented from their decision and argued that it was an unreasonable burden for states to impose taxes on interstate commerce without any regard for its impact or consequences. He further stated that such taxation would be oppressive to railroads operating across multiple states as they would have to pay different rates depending upon which state they were doing business in at any given time; thus creating an unequal playing field between them and other businesses not subject to such taxation schemes. In conclusion, Justice Field believed that allowing states to impose these types of taxes could lead down a slippery slope where all forms of interstate commerce are taxed differently by each individual state with no uniformity or consistency whatsoever - something he felt should be avoided at all costs if we are truly going uphold our constitutional rights under the Fourteenth Amendment's Due Process Clause